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entitled 'Diploma Mills:  Diploma Mills Are Easily Created and Some Have 
Issued Bogus Degrees to Federal Employees at Government Expense' which 
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Testimony:  

Before the Subcommittee on 21st Century Competitiveness: 
Committee on Education and the Workforce: 
House of Representatives: 

For Release on Delivery Expected at 11: 00 a.m. EDT: 
Thursday, September 23, 2004: 

Diploma Mills: 

Diploma Mills Are Easily Created and Some Have Issued Bogus Degrees to 
Federal Employees at Government Expense: 

Statement of Robert J. Cramer: 
Managing Director: 
Office of Special Investigations: 

GAO-04-1096T: 

Mr. Chairman and Members of the Subcommittee: 

I am pleased to be here today to discuss work performed by GAO's Office 
of Special Investigations (OSI) related to degrees from "diploma 
mills." For purposes of this overview, we defined "diploma mills" as 
nontraditional, unaccredited, postsecondary schools that offer degrees 
for a relatively low flat fee, promote the award of academic credits 
based on life experience, and do not require any classroom instruction. 
Over the past 3 years, OSI has purchased degrees from a diploma mill 
through the Internet, created a diploma mill in the form of a 
fictitious foreign school, investigated whether the federal government 
has paid for degrees from diploma mills for federal employees, and 
determined whether high-level federal employees at certain agencies 
have degrees from diploma mills. My testimony today summarizes our 
investigative findings.

Purchasing Degrees from a Diploma Mill: 

In response to a request from the Senate Permanent Subcommittee on 
Investigations of the Committee on Governmental Affairs, OSI purchased 
two degrees from a diploma mill through the Internet. After identifying 
"Degrees-R-Us" as a diploma mill, our investigator held numerous 
discussions in an undercover capacity with its owner. Posing as a 
prospective student, the investigator first contacted Degrees-R-Us to 
obtain information regarding the steps to follow in purchasing degrees. 
Following those instructions, we purchased a Bachelor of Science degree 
in Biology and a Master of Science degree in Medical Technology. The 
degrees were awarded by Lexington University, a nonexistent institution 
purportedly located in Middletown, New York. We provided Degrees-R-Us 
with references that were never contacted and paid a $1,515 fee for a 
"premium package." The package included the two degrees with honors and 
a telephone verification service that could be used by potential 
employers verifying the award of the degrees.

Creating a Diploma Mill: 

OSI also created a diploma mill to test vulnerabilities in the Federal 
Family Education Loan Program (FFEL). We created Y'Hica Institute for 
the Visual Arts, a fictitious graduate-level foreign school purportedly 
located in London, England. We first created a bogus consulting firm 
that posed as Y'Hica's U.S. representative and the principal point of 
contact with the Department of Education (Education). In addition, we 
created a Web site and set up a telephone number and a post office box 
address for Y'Hica. Using counterfeit documents, we obtained 
certification from Education for the school to participate in the FFEL 
program. Education has since reported that it has taken steps to guard 
against the vulnerabilities that were revealed by our investigation.

Investigating Whether the Federal Government Has Paid for Degrees from 
Diploma Mills: 

The Homeland Security Act amended section 4107 of title 5, U.S. Code, 
by allowing federal reimbursement only for degrees from accredited 
institutions. Specifically, section 4107 states that an agency may "pay 
or reimburse the costs of academic degree training … if such training … 
is accredited and is provided by a college or university that is 
accredited by a nationally recognized body." (Emphasis supplied.) For 
purposes of this provision, a "nationally recognized body" is a 
regional, national, or international accrediting organization 
recognized by Education.[Footnote 1] Because the law governs only 
academic degree training, it does not preclude an agency from paying 
for the costs of individual training courses offered by unaccredited 
institutions. Prior to the enactment of the Homeland Security Act, 
federal agencies were not authorized to pay for employee academic 
degree training unless the head of the agency determined that it was 
necessary to assist in recruitment or retention of employees in 
occupations in which the government had a shortage of qualified 
personnel.

To investigate whether the federal government has paid for degrees from 
diploma mills, we requested that four such schools provide information 
concerning (1) the number of current and former students identified in 
their records as federal employees and (2) the payment of fees for such 
employees by the federal government. In addition, posing as a 
prospective student who was employed by a federal agency, our 
investigator contacted three diploma mills to obtain information on how 
he might have a federal agency pay for a degree. We also requested that 
eight federal agencies--the Departments of Education, Energy (DOE), 
Health and Human Services (HHS), Homeland Security (DHS), 
Transportation (DOT), and Veterans Affairs (VA); the Small Business 
Administration (SBA), and the Office of Personnel Management (OPM)--
provide us with a list of senior employees, level GS-15 (or equivalent) 
or higher, and the names of any postsecondary institutions from which 
such employees had reported receiving degrees. We compared the names of 
the schools on the lists provided by these agencies with those that are 
accredited by accrediting bodies recognized by Education. We also 
requested that the agencies examine their financial records to 
determine if they had paid for degrees from unaccredited schools.

Several factors make it extremely difficult, if not impossible, to 
determine the extent of unauthorized federal payments for degrees 
issued by diploma mills. First, the data we received from both schools 
and federal agencies understate the extent to which the federal 
government has made such payments. Additionally, the way some agencies 
maintain records of payments for employee education makes such 
information inaccessible. For example, HHS responded to our request for 
records of employee education payments by informing us that it could 
not produce them because it maintains a large volume of such records in 
five different accounting systems, has no way to differentiate academic 
degree training from other training, and does not know whether payments 
for training made through credit cards are captured in its training 
payment records.

Moreover, diploma mills and other unaccredited schools modify their 
billing practices so students can obtain payments for degrees by the 
federal government. Purporting to be a prospective student, our 
investigator placed telephone calls to three schools that award 
academic credits based on life experience and require no classroom 
instruction:  Barrington University (Mobile, Alabama); Lacrosse 
University (Bay St. Louis, Mississippi); and Pacific Western University 
(Los Angeles, California). These schools each charge a flat fee for a 
degree. For example, fees for degrees for domestic students at Pacific 
Western University are as follows:  Bachelor of Science ($2,295); 
Master's Degree in Business Administration ($2,395); and PhD ($2,595). 
School representatives emphasized to our undercover investigator that 
they are not in the business of providing, and do not permit students 
to enroll for, individual courses or training. Instead, the schools 
market and require payment for degrees on a flat-fee basis.

However, representatives of each school told our undercover 
investigator that they would structure their charges in order to 
facilitate payment by the federal government. Each agreed to divide the 
degree fee by the number of courses a student was required to take, 
thereby creating a series of payments as if a per course fee were 
charged. All of the school representatives stated that students at 
their respective schools had secured payment for their degrees by the 
federal government.

Information we obtained from two unaccredited schools confirms that the 
federal government has paid for degrees at those schools. We asked four 
such schools that charge a flat fee for degrees to provide records of 
federal payments for student fees:  California Coast University (Santa 
Ana, California); Hamilton University (Evanston, Wyoming); Pacific 
Western University (Los Angeles, California); and Kennedy-Western 
University (Thousand Oaks, California).

Pacific Western University, California Coast University, and Kennedy-
Western University provided data indicating that 463 of their students 
were federal employees. Pacific Western University reported that it 
could not locate any records indicating that federal payments were 
made, although this claim directly contradicts representations made to 
our undercover investigator by a school representative that federal 
agencies had paid for degrees obtained by Pacific Western University 
students. California Coast University and Kennedy-Western University 
provided records indicating that they had received $150,387.80 from 
federal agencies for 14 California Coast University students and 50 
Kennedy-Western University students. Hamilton University failed to 
respond to our request for information.

After identifying from school records the federal agencies that made 
payments to California Coast and Kennedy-Western, we requested that 
DOE, HHS, and DOT provide records of their education-related payments 
to schools for employees during the last 5 years. As previously 
discussed, HHS advised us that it could not provide the data. DOE and 
DOT provided data that identified additional payments of $19,082.94 for 
expenses associated with Kennedy-Western, which Kennedy-Western had not 
previously identified for us. Thus, we found a total of $169,470.74 in 
federal payments to these two unaccredited schools.

However, a comparison of the data received from the schools with the 
information provided by DOE and DOT shows that the schools and the 
agencies have likely understated federal payments. For example, 
Kennedy-Western reported total payments of $13,505 from DOE for three 
students, while DOE reported total payments of $14,532 to Kennedy-
Western for three different students. Thus, DOE made payments of at 
least $28,037 to Kennedy-Western. Additionally, DOT reported payments 
of $4,550 to Kennedy-Western for one student, but Kennedy-Western did 
not report receiving any money from DOT for that student.[Footnote 2]

Determining Whether High-Level Federal Employees Have Degrees from 
Diploma Mills: 

On the basis of the information we obtained from eight agencies, we 
determined that some senior-level employees obtained degrees from 
diploma mills. Specifically, we requested that the agencies review the 
personnel folders of GS-15 (or equivalent) and above employees and 
provide us with the names of the postsecondary institutions from which 
such employees reported receiving academic degrees. The eight agencies 
were Education, DOE, HHS, DHS, DOT, VA, SBA, and OPM. The agencies 
informed us that their examination of personnel records revealed that 
28 employees listed degrees from unaccredited schools, and 1 employee 
received tuition reimbursement of $1,787.44 in connection with a degree 
from such a school.

We interviewed several federal employees who had reported receiving 
degrees from unaccredited schools. These employees included three 
management-level DOE employees who have emergency operations 
responsibilities at the National Nuclear Security Administration and 
security clearances. We also found one employee in the Senior Executive 
Service at DOT and another at DHS who received degrees from 
unaccredited schools for negligible work.

Moreover, we believe that the agencies are not able to accurately 
determine the number of their employees who have diploma mill degrees. 
The agencies' ability to identify degrees from unaccredited schools is 
limited by a number of factors. First, diploma mills frequently use 
names similar to those used by accredited schools, which often allows 
the diploma mills to be mistaken for accredited schools. For example, 
Hamilton University of Evanston, Wyoming, which is not accredited by an 
accrediting body recognized by Education, has a name similar to 
Hamilton College, a fully accredited school in Clinton, New York. 
Moreover, federal agencies told us that employee records may contain 
incomplete or misspelled school names without addresses. Thus, an 
employee's records may reflect a bachelor's degree from Hamilton, but 
the records do not indicate whether the degree is from Hamilton 
University, the unaccredited school, or Hamilton College, the 
accredited institution. Further, we learned that there are no uniform 
verification practices throughout the government whereby agencies can 
obtain information and conduct effective queries on schools and their 
accreditation status. Additionally, some agencies provided information 
about only the most recent degrees that employees reported receiving.

Concluding Remarks: 

Our investigations revealed the relative ease with which a diploma mill 
can be created and bogus degrees obtained. Furthermore, the records 
that we obtained from schools and agencies likely understate the extent 
to which the federal government has paid for degrees from diploma mills 
and other unaccredited schools. Many agencies have difficulty in 
providing reliable data because they do not have systems in place to 
properly verify academic degrees or to detect fees for degrees that are 
masked as fees for training courses. Additionally, the agency data we 
obtained likely do not reflect the true extent to which senior-level 
federal employees have diploma mill degrees. This is because the 
agencies do not sufficiently verify the degrees that employees claim to 
have or the schools that issued the degrees, which is necessary to 
avoid confusion caused by the similarity between the names of 
accredited schools and the names assumed by diploma mills. Finally, we 
found that there are no uniform verification practices throughout the 
government whereby agencies can obtain information and conduct 
effective queries on schools and their accreditation status.

Mr. Chairman, this concludes my prepared statement. I would be happy to 
respond to any questions that you or Members of the Subcommittee may 
have.

Contacts: 

For further information about this testimony, please contact Robert J. 
Cramer at (202) 512-7227, Andrew O'Connell at (202) 512-7449, or Paul 
Desaulniers at (202) 512-7435.

(601269): 

FOOTNOTES

[1] 5 C.F.R. § 410.308(b).

[2] Our investigation was limited to direct federal payments to schools 
and did not include federal reimbursements of school fees to employees.